RoHS and WEEE, answered for importers

• RoHS is a product-content rule that rides on CE: compliance is declared in the same EU Declaration of Conformity as LVD, EMC and RED. There is no separate "RoHS certificate" — what exists are test reports.
• WEEE is extended producer responsibility for electronics: national registration, volume reporting, financing of take-back. Same family as packaging EPR, same per-member-state structure, no EU-wide register.
• Neither replaces the other, and neither replaces the CE directives — an imported gadget normally needs the CE assessment, RoHS substance compliance and WEEE registration, all three.

Product-level context: electronics carries the full picture; the CE page covers the directives themselves.

• The phthalates were added by Delegated Directive (EU) 2015/863; since 22 July 2021 all ten apply to medical devices and monitoring/control instruments too.
• Scope has been open since 22 July 2019: all electrical and electronic equipment is in unless it is specifically excluded (Annex II — military equipment, large-scale fixed installations, space equipment and the like) or exempted substance-by-substance (Annex III/IV).
• Cables and spare parts count — a compliant device with a non-compliant cable is a non-compliant product.
• Enforcement is through the DoC: your supplier's Declaration of Conformity must state RoHS compliance, and the technical file must hold the substance evidence. That is what "RoHS compliant" has to mean when a supplier claims it in an e-mail.

• Renewal is not automatic: an application must be filed before expiry (in practice 18 months ahead), and re-justified against alternatives — exemptions lapse when substitutes become available.
• From 13 August 2027, ECHA runs the exemption process under Directive (EU) 2025/2456, replacing the Commission's own assessment, with a 45-day completeness check. Expect the rhythm of RoHS exemptions to start resembling REACH: dossier quality matters.
• No recast is coming: the Commission's review concluded RoHS is fit for purpose; changes continue as targeted amendments and exemption decisions, not a new directive.

What to do: list every exemption your products rely on, put the expiry dates in the compliance calendar, and ask suppliers in writing which exemptions their RoHS declarations assume — most have never checked.

• Registration is national — Germany's Stiftung EAR, France's ADEME ecosystem, each state its own register, number and fee. No EU-wide number exists, exactly like packaging EPR.
• Register before the first sale: several states treat selling unregistered as an offence in itself. Germany set the precedent marketplaces follow: since 2023, Amazon.de must block listings of sellers without a valid WEEE number — and marketplaces elsewhere ask the same question at onboarding.
• Not established in the member state? Appoint an authorised representative there for your WEEE obligations (Article 17) — one more registration decision per country you ship to.
• Financing: consumer equipment (B2C) through a compliance scheme or — where the state allows — individual financing with proof of insurance; business equipment (B2B) by contract with your customer unless agreed otherwise.
• The crossed-out wheelie bin goes on the product itself, visibly and durably — not only on the box. Products without it can be refused at re-sale and at marketplace checks.

• As of 4 September 2026 the proposal has not been tabled — this is a Commission timetable, not law. When it lands it will move fast, because it rides in a package. The calendar picks it up the day it is published.
• RoHS changes are quieter but real: the ECHA takeover on 13 August 2027 and the exemption expiries of 2027 (above) are already law.
• Batteries inside your product are a separate track: Regulation (EU) 2023/1542 adds battery duties on top of RoHS and WEEE — collection information, and the battery passport from 18 February 2027 for LMT, EV and industrial batteries above 2 kWh.

1. Determine whether it is EEE: does it need electric current or electromagnetic fields to do its primary job? Then RoHS and WEEE apply — batteries-only counts, passive cables count.
2. RoHS evidence: per-product substance declarations or test reports for the ten substances, tied to the model you import — and a written list of every exemption relied on, with its expiry date.
3. The DoC must name RoHS alongside the CE directives — a CE declaration that omits RoHS on an EEE product is incomplete on its face.
4. WEEE: register in each state you sell into, before the first sale, with an authorised representative where you are not established. This is per country, like packaging EPR — the product check counts your countries.
5. Marking and marketplace fields: the crossed-out bin on the product; the WEEE register number in Seller Central and any other platform that asks.
6. Keep the file for ten years — DoC, test reports, registrations, volume reports — and review it whenever an exemption lapses or the WEEE revision lands.